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Facts
The assessee, a partnership firm, filed a return declaring a loss for AY 2018-19. The Assessing Officer disallowed Rs. 58,69,491/- on account of compression and blasting expenses, stating they belonged to an earlier year despite payment in the current year.
Held
The Tribunal held that since the expenses were incurred exclusively for business purposes and the liability had crystallized in the relevant previous year, no disallowance was warranted merely because the payment was made in the subsequent year. Therefore, no addition was called for.
Key Issues
Whether disallowance of expenses is justified when liability crystallized in the previous year, even if payment was made in a subsequent year.
Sections Cited
250, 143(3)
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Income Tax Appellate Tribunal, SURAT BENCH, SURAT
(Assessment Year: 2018-19) Shree Ram Minings, Income Tax Officer, Vs. Jamanpada Navsari, Ward-5, Navsari-396040. Navsari. [PAN : ACRFS4648B] (Appellant) .. (Respondent) Appellant by : Shri Rasesh Shah, AR Respondent by: Shri Ajay Uke, Sr. DR Date of Hearing 21.01.2026 Date of Pronouncement 23.01.2026 O R D E R PER DR. B.R.R. KUMAR, VICE-PRESIDENT:-
This appeal has been filed by the Assessee against the order dated 10.06.2025 passed by the Ld. Commissioner of Income-Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (“the CIT(A) in short), under Section 250 of the Income-tax Act, 1961 (“the Act”), relating to the Assessment Year 2018-19.
The assessee is a partnership firm carrying on business in the name and style of Shree Ram Minings and derives income from business. The assessee filed its return of income for Assessment Year 2018-19 declaring a loss of Rs.3,492/- and maintains its books of account under the mercantile system of accounting. During the course of assessment proceedings, the Assessing Officer disallowed an amount of Rs.58,69,491/- on account of compression and blasting expenses on the ground that the expenses pertained to an earlier year, though payment was made during the year under consideration. Before us, the assessee furnished complete details of the blasting expenses along with evidence of tax deducted at source thereon. Since the expenses were incurred wholly and exclusively for the purposes of business and liability had crystallized during the relevant previous year, merely because the payment was made
We have carefully examined the records and, in view of the details furnished regarding the blasting expenses incurred by the assessee, we hold that no addition is called for on this account.
In the result, the appeal of the assessee is allowed.
The order is pronounced in the open Court on 23.01.2026.